A disbarred attorney who was a former tax fraud litigation specialist was liable for a §6663 fraud penalty of almost $2 million for failing to report income. The income stemmed from representing clients who were victims of clergy abuse, and when the case settled, the taxpayer placed all of the settlement funds into his personal UBS account, comingling client funds with his own. He also used interest earned on the funds for personal purposes, and did not report the 60% fee for his services representing these clients. (Isaacson v. Comm., TCM 2020-17)
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